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BADideas.fund ESG Policy (SFDR Article 6)

Date of Last Review: July 2025
Date of Next Review: June 2026
Approved by: BAD Company AIFP SIA Management Board

Mandatory disclosures under Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector ("SFDR")

  • Introduction

    • BAD Company AIFP SIA (“BADideas.fund”) is a Latvia-based alternative investment fund manager focused on early-stage technology startups. We recognize the importance of environmental, social, and governance (ESG) considerations and are committed to integrating responsible investment practices across our fund operations and portfolio.

    • This ESG Policy outlines how ESG principles inform our investment philosophy, due diligence processes, portfolio engagement, and reporting activities, in alignment with SFDR Article 6. While sustainability risks are not currently decisive in our investment decisions, we recognize their importance and evaluate them proportionately to our fund's scale and strategy.

  • Purpose and Principles

    • Our ESG approach supports our broader mission: to invest in teams building innovative, resilient, and responsible companies. ESG is not a compliance checklist, but a toolset for better risk management, stronger governance, and long-term value creation.

    • We aim to:

      • maintain ESG awareness throughout our investment lifecycle

      • encourage ESG progress in portfolio companies without imposing undue burden

      • comply with all applicable ESG-related disclosures and regulatory expectations

  • ​Investment Process

    • Sourcing and Due Diligence

      • We incorporate ESG considerations during the due diligence phase. Specifically:

        • ESG risks and opportunities are evaluated during investment screening

        • Each Investment Memorandum pertaining to the fund’s investments includes a section on ESG considerations

        • The Investment Committee discusses ESG findings as part of the final decision process

      • While ESG factors may not be decisive, they are reviewed as part of our risk lens and may influence investment outcomes. We do not invest in startups that:

        • Operate in sectors restricted by EU or national regulations

        • Violate human rights standards or are involved in high-risk compliance categories

    • Ownership and Portfolio Engagement

      • While BADideas.fund typically takes a minority stake, we engage with portfolio companies to promote responsible growth. This includes:

        • Regular founder check-ins, where ESG topics may be discussed

        • Tracking progress on company-specific milestones, which may include ESG-related objectives

        • Encouraging founders to surface ESG risks, compliance needs, or progress voluntarily

        • Providing support through expert networks when operational or governance gaps arise

      • We maintain a general awareness of ESG progress in the portfolio but do not mandate formal ESG reporting, given our Article 6 classification. These engagements are non-binding, context-specific, and do not imply a formal ESG performance requirement.

  • Illustrative ESG Themes in Practice

    • Our portfolio includes companies contributing to:

      • Sustainable product development and responsible manufacturing

      • Inclusive, tech-enabled job creation in emerging regions

      • Transparent governance and innovation-driven business models

    • These themes are not mandated but reflect the types of outcomes we support where aligned with company growth. BADideas.fund does not currently rely on external ESG labels, ratings, or industry credentials in its public communications or investment decisions.

  • Reporting and Transparency

    • We maintain a reporting process aligned with regulatory and stakeholder expectations:

      • ESG topics are addressed in internal reviews and investor communications

      • A designated compliance function oversees ESG-related responsibilities

      • Relevant ESG data is collected through portfolio engagement and stored securely for 10 years post-investment

  • Scope and Review

    • This Policy applies to all BADideas.fund investment activities, including those under current and future fund vehicles. As part of our annual review, BADideas.fund monitors evolving sustainability disclosure standards and greenwashing guidance issued by regulators such as ESMA, to ensure this Policy remains clear, proportionate, and compliant.
       

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